ML20215M025
| ML20215M025 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/04/1987 |
| From: | Urbanik T SUFFOLK COUNTY, NY, TEXAS A&M UNIV., COLLEGE STATION, TX |
| To: | |
| References | |
| CON-#287-3424 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8705130063 | |
| Download: ML20215M025 (76) | |
Text
s + 21 nursoc9ew22 pc#4 TIMNSCluPI' w
OF PROCEEDINGSm me UNITED STATES OF AMERICA 0FFE 3 00CKETir13 :". M WICF.
NUCLEAR REGULATORY COMMISSION SPANC" BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - - - - - - - - - - - - - - - - - -x In the Matter of:
Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (ASLBP No. 86'533-01-OL)
(Shoreham Nuclear Power Station, Unit 1)
- - - - - - - - - - - - - - - - - - - -x DEPOSITION OF THOMAS URBANIK II Hauppauge, New York Wednesday, March 4, 1987 ACE-FEDERAL REPORTERS, INC.
Stertoty;vlh vrters 7
444 North CapitolStreet
['3 Washington, D.C. 20001 d
(202) 347-3700 Nationwide Coverage 800-336-6646 8705130063 870304 PDR ADOCK 05000322
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1
.1' 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
5 In the Matter of:
r 6
L'ONG ISLAND LIGHTING COMPANY Docket NO.
(Shoreham Nuclear Power Station, 50-322-OL-5 7
Unit 1)
(ASLBP No.
86-533-01-OL) s_
9 10 DEPOSITION OF THOMAS URBANIK, II, a 11 witness herein, taken at the offices of the Suffolk
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12 County Attorney, Building 158, North County Complex, 13 Veterans-Memorial Highway, itauppauge, New York, on 14 Wednesday, March 4,
1987, before Debra Stevens, a 15 shorthand reporter and notary public, within and for 16 the State of New.
17 York.
18 19 20 TANKOOS REPORTING COMPANY. INC.
21 150 Nassou Street 223 Jericho Turnpike New York, N.Y.
10038 Mineola, New York 11501 22 (212)349-9692 (516)741-5235 0)
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A.J'_P_ _EJllJ_C _F _S__ L s
2
'HUNTON & WILLIAMS, Attorneys for LILCO 3
707 E.
Main Street Richmond, Virginia 23212 4
BY:
MARY JO LEUGERS, ESO.
5 STEPHEN W.
MILLER, ESO.
6 RICHARD J.
ZAHNLEUTER, ESO.
7 Deputy Special Counsel to the Governor Attorney for State of New York 8
Executive chamber Capitol, Room 229 9
Albany, New York 12224 10 KIRKPATRICK & LOCKHART 11 Attorneys for SUFFOLK COUNTY
/
South Lobby, 9th Floor
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12 1800 M Street, N.W.
Washington, D.C.
20036-5891 13 BY:
CHRISTOPHER M.
McMURRAY, ESO.
14 RICHARD G.
BACHMANN, ESO.
15 Attorney on behalf of the witness U.S.
Nuclear Regulatory Commission 16 Washington, D.C.
20555 17 18 IT IS STIPULATED AND AGREED that the 19 within examination may be subscribed and sworn to 20 before any notary public with the same force and 21 effect as though subscribed and sworn to before this 22 court.
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Lfl._Q El 2
WJTNESE EXAl1TIIAT_IRN.
3 Thomas Urbanik. II 4
4 E X t[I D I l
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PES.CfUf_Il0N pef XR=
5 Urbanik No. 1 Curriculum vitae.
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7 8
9 10 11 0
12 13 14 15 16 17 18 19 20 21 22 O
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2 1
THOMAS URBANIK, II 2-having been first duly sworn, was examined and 3
testified as follows:
4 EXAMINATION BY MR. McMURRAY:
5 Q.
Dr. Urbanik, my name is Christopher 6
McMurray.
I represent Suffolk County.
Today we are 7
poing to be talking about LILCO's three reception 8
centers and the routes leading to those centers.
9 When I talk about the reception centers. I am 10 talking about LILCO's Roslyn, Bellmore and it' Hicksville operations centers.
Do you understand r
12 that?
13 A.
Yes, sir.
14 Q.
Okay.
15 Dr. Urbanik, could you please spell 16 your name for the record and state your business 17 address?
18 A.
Thomas.
T-H-O-M-A-S,
- Urbanik, 19 U-R-B-A-N-t-K, the second.
Texas Transportation 20 Institute. Texas A&M University, College Station, 21 Texas 77843.
22 You also asked my occupation?
In that O
COMPUTER AIDED TRANSCRIPTION / keyword index
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right?
2 Q.
No. I didn't.
3 A.
Oh, I'm sorry.
4 Q.
I know your occupation.
5 Dr. Urbanik. you have been identified 6
na a witness in the proceedings which are coming up 7
on LILCO's three reception centers and I would like 8
to ask you what you will be testifying on at that 9
honring.
10 A.
Essentially, the issue of trnffic and 11 transportation nround the reception centers.
12 Q.
By that you menn you will be looking at 13 the ronda nnd intersections lending up to the 14 reception centers from the EPZ?
15 A.
I will be reviewing the analyses that 16 have been performed reintive to whether or not 17 evacueen from the EPZ can, in fnot, obtnin accean to 18 the reception centern.
19 Q.
When you any "the nnnlysis," are you 20 referring to a report which we have been onlling KLD f
21 1927 22 A.
Yen, sir.
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1 Q.
Do you have a copy of that with you, by 2
the way?
i 3
A.
Yes, sir.
4 Q.
At some point we will be referring to r
5 that and I would apprecinte it if you could refer to 6
your own copy.
I have mine.
i 7
Sefore we get to that, will you be 8
reviewing at all the inaue of the circuintion of 9
traffic within the sites themselves?
10 A.
I am unsure of that.
11 Q.
Have you had any discussions with i
12 anyone about whether you will be testifying on that 13 insue?
14 A.
I have talked to my nttorney nbout it.
15 O.
At thin time, have you reviewed any i
16 materinia regarding circulation of traffic within 1
17 the sites themselves?
18 A.
Nothing other than what's in the 19 report.
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i 20 0.
Again, you nre referring to KLD 1927 21 A.
Yes. nir, 22 Q.
Will you be reviewing nt all the amount i
COMPUTER AIDED TRANSCRIPTION / keyword index
7 P
rm 1
of time necessary to monitor cars or people?
2 A.
I don't know the answer to that.
l 3
0.
Have you visited the reception centers?
4 A.
No, sir.
5 O.
Do you intend to?
6 A.
Yes, sir.
7 0.
When do you intend to do that?
8 A.
Tomorrow.
Well, the aren surrounding 9
the reception centers.
10 Q.
Do you intend to go on the grounds of 11 the reception contors?
)
12 A.
Probably not.
13 Q.
At this point, I take it you don't feel 14 it's necessary for you to go on the sites in order 15 for you to form your testimony?
t 16 A.
Well. I think I have previotJaly 17 specified that I don't--thnt there are some issues 18 that are currently unresolved in terms of what is 19 going on within the sites.
So, I can't answer that 20 question.
21 0.
I take it, then, tomorrow you intend to 22 Look at the ronds nround the reception centers?
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A.
Right.
2 Q.
Can you tell me briefly how you are 3
going to conduct your review of those roads?
4 A.
Mainly by driving in my auto, rented 5
car.
6 Q.
Which roads will you be driving?
7 A.
Well, it's hard to say.
I will 8
essentially go to the sites and then work backward 9
there and look over the routes and go as far as I 10 deem is necessary.
11 O.
Well, do you intend to drive the paths
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12 designated in KLD 192 as routes going to the 13 reception centers?
14 A.
Portions of them, anyway.
15 O.
Do you intend to drive any other routes 16 to see if they are possible evacuation routes for 17 ovacuees?
18 A.
I will do whatever I think is necessary 19 to satisfy myself as to the issue of gaining access 20 there.
21 Q.
Well, at this time, do you have any 22 intention to drive any of the routes other than COMPUTER AIDED TRANSCRIPTION / keyword index
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1 those designated in KLDTR 192'as evacuation routes?
~2;
.A.
Oh, I would probably look at--look at
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.some alternatives, partly Just to satisfy myself as 4'
to how.the particular routes were established.
5 Q.
Can you tell.me now what the routes.are 6
.that ~have been designated in the analysis, the KLD 7
. analysis, as evacuation routes to.the reception 8
' centers?
3
'9-A.
Well, I have to refer to the document.
10
~I don't have a mental picture of the evacuation 11-routes.
12 Q.
Do you intend to take any measurements 13 at eny particular intersections or roadway sections?
14--
A.
Probably not.
15 Q.
Other than driving the roads tomorrow 16 and reviewing the KLD analysis which you have in 17 front.of you, do.you intend to conduct any other 18 analyses in preparation for your testimony?
19 A.
Not at this time.
20 O.
Have you reviewed the LILCO plan with 21-respect to these newly designated reception centers?
22 A.
I don't understand the question.
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10 i
Q,'
1 Q.
I know that a few years ago you 2
testified on the adequacy of the evacuation time 3
' estimates in the LILCO plan.
Do you recall that?
4 A.
Yes, sir.
5 O.
Since that time, have you reviewed any 6
portions of the LILCO plan, any subsequent 7
revisions?
8 A.
Only some material that I have recently 9
been given, which is incomplete.
But on revision 10 eight, I guess, of the plan.
11 Q.
So you have reviewed at least some
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12 portions of revision eight of the LILCO plan?
13 A.
Yes, sir.
14 Q.
And those portions pertain to the new 15 reception centers?
16 A.
Yes, sir.
17 Q.
Can you tell me what portions of the 18 LILCO plan you have reviewed?
If you can, maybe 19 Just give me the OPIP numbers or page numbers.
20 A.
OPIP 4.2.3, consisting of 29 pages, 21 more or less, plus 4.3.1, page 2,
6, 6A; 4.5.1, 22 pages 7, 8,
28, 29, 38, 39, 40, 41; OPIP 5.1.1, page
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17, 18, 19.
2 That's, I think, all the documents that 3
have an OPIP reference.
4 Q.
Have you reviewed any other portions of 5
the LILCO plan that may not have been designated as 6
OPIPs but are, nevertheless, parts of the LILCO 7
plan?
8 MR. McMURRAY:
Off the record.
9 (Discussion held off the record.)
10 A.
This is a portion of the plan.
It's 11 not' complete.
In fact, it's largely mater!.al I have
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12 seen before as part of the original-time estimate, 13 part of the time estimate study.
But it also has 14 some new material on reception centers.
You want 15 page numbers?
16 Q.
No.
That's fine.
17 What other documents have you reviewed 18 regarding LILCO's reception centers?
If you could 19 Just list them.
20 A.
Document dated December 11,
'86, 21 memorandum and order ruling on LILCO motion to 22 reopen and record and remand of coliseum issue; l
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COMPUTER AIDED TRANSCRIPTION / keyword index
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'R) 1 document LILCO February 4
'87, LILCO's responses 2
and objections to intervenor's first set of 3
interrogatories.
4 Q.
.Okay.
5 A.
This is an earlier draft of, I believe, 6
the material that's essentially in that OPIP.
It's 7
transmitted as a letter of February 28,
'87, from 8-Hunton & Williams to Richard J.
Zahnleuter --
9 Zahnleuter--sorry.
10 MR. ZAHNLEUTER:
You said it right.
11 THE WITNESS:
A copy of a document that p_.
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12 was recently transmitted on March 2nd, which is NRC 13 staff supplemental responses.
And LILCO document of 14 Februsey 20,
'87, LILCO's responses and objections 15 to-intervenor's second set of interrogatories dated 16 February 6th.
17-Q.
I notice that you have a pile of 18 documents in front of you.
Could you quickly go 19 through there to make sure you have told me all the 20 documents that you have reviewed regarding LILCO's 21 reception centers?
22 A.
You want me to list them again?
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1 Q.-
No. :
I Just want you to go through them
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2 and ~ see - if you have missed any.
2[
(Pause.)
1
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.A..
We have this one.
February 9th 5
memorandum and order of ruling on LILCO's-6 intervenor's' motion for reconsideration of schedule.
7 Here is one hiding on the bottom.
8 January 28, 1987,- Suffolk County, State of New' York 9
and. Town of. South Hampton's first set of 10 interrogatories and reauest for production of 11 documents.
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O.
Are there any other documents that you
~13 may-have reviewed but didn' t bring with you today 14 regarding LILCO's reception centers?
15 A.
No, I don't think so.
16-O.-
Okay.
.17 A.
Oh, yes.
I.take that back.
A huge r
18 stack of documents which are essentially a series.of J. '
19 work done by.Lieberman, a Xerox of all their t
20 calculations.
That's essentially what's in there.
4-21 Q.
When you say "Lieberman," you are i
22 talking about--
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1 41 a
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-1' A..
KLD.
The. computations that went into
.2
' KLDTR 192, which are-their notes.
3 Q.-
Mr. Lie'berman is one of the principals 4
of KLD?
5 A.
Right.
6 Q.
Have you been in contact with Mr.
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7 Lieberman at all-about his' analysis?
8-A.
'Yes, sir.
'9
.Q.
When did you contact Mr. Lieberman?
10 A.
It_was either yesterday or-the day ill-before.-
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12 Q.
Did.he contact you or did you contact 13 him?
14 A.
.I contacted him.
f 15
. Q.
'What was'the purpose of your phone i
- 16 call?
q-..
l 17' A.
I had some questions regarding this.
I
~18 Q.
What were those questions?
P-19 A.
In regards to page 19 of his document, 20 whether in-fact they had considered the traffic
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- 21 exiting from the reception center to Sunrise Highway I
j; and how it impacted on the intersection of Sunrise COMPUTER AIDED TRANSCRIPTION / keyword index
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. Highway and Newburgh Road.
2-lAnd.in regard to figure-A-8 on Page 3?
A-11, why they had not coun'ted traffic on Newbridge 4-Road southbound.
5 I guess I also. generally discussed the-6' issue'of whether.or not they had included--to what.
- 7-extent D'affic control was included in their 8~
analysis.
..9 Q.
What do you mean when-you say " traffic 10'
'c on t ro l " ?.
11 A.
Some form of traffic guides, I guess,
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- 12 is-the official term being used, to encourage people
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13 to make particular movements.
14 Q.
Were-there any-other issues you 15 discussed with Mr. Lieberman?
-16 A.
I do not'believe so.
17 Q.
Let's go back to the--
i-18-A.
He. apologized for the inability to read I
19 a lot of his cocuments.
20 Q.
You mean poor copy quality or that some t
21 information was missing?
g 22 A.
No.
It was penciled--not well organized O
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and makes it very difficult to review.
2 Q.
Let's go back to~ the stack of documents 3'
you said you received regarding Mr. Lieberman's 4
calculations..
5 Have you reviewed those underlying 6
documents?
7 A.
Just briefly.
8 O.
Do you intend to review them more 9
thoroughly?
10 A..
Yes, sir.
11 Q.
What were you looking for in your
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12 review of the underlying documents?
13 A.
Essentially, I am looking for the 14 methodology that is used and the appropriateness 15 problem at hand, and essentially spot checking some 16 calculation to make sure that the calculations are 17 correct.
Q.
Have you formed any preliminary 18 19 opinions, based on the review you have conducted.so 20 for of the underlying documents, as to whether or 21 not the calculations were done correctly?
22 A.
Oh, I have some concerns.
Obviously, em
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-it' appears _that they were done rather hurriedly, i
2 which would lead one.to be concerned about possible
. '3 errors.
4
.What
,Q.
.Could you-elaborate, please?
4.
-5' makesLyou believe that-the. calculations were done 6
hurriedly?
7 A.
Just looking at'the. documentation.
8 Penciled. notes and stuff.
-9 Q.
Have you found errors in calculations?
-10 A.
- No, sir.
11'-
Q.
Will-you be looking for such errors s.
i' 12 whenDyou conduct a more thorough review of the
-13 underlying documents?
14 A.~ -
Yes.
-- 15 '
.Q.
Regerding the methodology.used,-do you 16~
have any opinion at this-time, based on your 17 preliminary review of the underlying documents, as 18 to whether-or not'the methodology applied was-19' correct?
20 A.
My preliminary feeling is that the
- 21 methodology largely appears to be appropriate, but'I 22 do have some concern for some details.
..D Q
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1 Q.
Could you list those concerns for me?
2 A.
Tne concerns have to do with the 3
ability of the reception centers themselves to 4
accommodate the traffic, and concern about the 5
issues of--concern about the amount and extent of.
6 traffic-control and how that relates to the analysis 7
.that was performed.
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8 Q.
Any other concerns that you can think 9
of now?
10 A.
I think that pretty well would be my 11 preliminary feelings at this time, realizing that I 7~,
I I
12 haven't had a tremendous amount of time to look at 13 this.
14 Q.
How much time have you been able to 15 spend on this issue of LILCO's reception centers so 16 far?
17 A.
Probably, in aggregate, about a day.
18 No, it would be two days.
One day getting here.
19 Q.
Can you estimate approximately how much 20 more time you feel you are going to need to analyze 21 the documents and the roadway system in order for 22 you to give testimony on these issues?
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1 A.
Probably several days.
It's hard to 2
say, but I wouldn't anticipate an inordinate amount 3
of time.
I am not doing an independent study.
4 Q.
With respect to the ability of the 5
sites themselves to handle the traffic, do you have 6
any opinions right now on the ability of those sites
'7 to handle the traffic?
8 A.
It would be hard to say.
No, I have 9
not done any calculations that would lead me to 10 believe one way or another.
11 Q.
Do you have any preliminary concerns
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12 about the ability of the sites themselves to handle 13 the traffic?
5 14 A.
Well, certainly you have to know how 15 fast the vehicles can be accommodated and how many 16 atations.
Essentially, a simple queuing problem of 17 knowing the service rate and number of stations and 18 arrival rate and see whether or not the system can 1
19 handle it.
So, it's not a terribly difficult 20 analysis.
21 But if you've ever been in a bank when 22 the line is long and there is only one teller, you D.
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know what it's like to get backed up, whereas if you 2
have--all of a sudden add three more telleres, the 3
line goes away.
4 Q.
Do you intend to do any analysis 5
regarding LILCO's ability to service the evacuees 6
coming to the reception centers in the time allotted 7
in the LILCO plan for each evacuee and arriving 8
vehicle?
9 A.
I don't necessarily anticipate doing 10 that, but I wouldn't be surprised if I did, either.
11 So, I think that's an unknown at this point.
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12 Q.
And it's true, isn't it, that the
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13 ability of the reception centers to handle the 14 f.ncoming traffic will be affected by that time--that 15 is, the amount of time it takes to handle each car 16 and arriving evacuee?
17 A.
The amount of time and the number of 18 stations that it's doing.
19 Q.
It is fair to say, isn't it, that an 20 increase in the amount of time necessary to monitor 21 arriving vehicles would increase the amount of time 22 required to do the whole population arriving at the o
COMPUTER AIDED TRANSCRIPTION / keyword index
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the same i
1 reception centers; correct?' Assuming 2
number'of monitoring stations?
-1 3
'A.
Yes.
4 Q.
Do you intend.to do any analysis 5.
regarding LILCO's ability to expand the number of 6
monitoring stations beyond those set forth in the v
7 plan?
i 8
A.
' No.
9 Q.
Do you intend to take any measurements 10 of the entrances and exits in order to determine 11.
whether or not the flow into the sites and out of
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-12 the sites can be accommodated?
13 A.
I don't anticipate that, but when I get
-14 out there I may change my mind.
15
-0.
To-the extent that you do review the-16 circulation of traffic.within the sites themselves, 17 will you be relying on the maps provided in the 18' LILCO plan to determine whether or not the site 19 circulation is adequate?
20 MR. BACHMANN:
I would like to make a j-21 quasi-objection, at least, here.
You are assuming 22 he is going to analyze whether the circulation is
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1 adequate, and I don't think that's ever been-2 established.
3 MR. McMURRAY:
It hasn't, but he didn't 4
say it's something he is not going to look at, 5
either.
To the extent there is a possibility he may 6
look at that, I would like to know right now whether 7
he has an understanding of what documents he might 8
rely on.
9 A.
I don't know the answer to that 10 question, given that I don't know that I am going to 11 do it.
So, it would be dependent on a number of
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12 things.
13 Q.
Do you have any opinions right now on 14 whether the maps of the LILCO facilities are 15 accurate?
16 A.
I have no opinion on that.
17 Q.
If you were going to look at the site 18 circulation question, would you want to assure 19 yourself that those maps are accurate?
20 A.
The maps would have to be accurate; 21 yes.
22 Q.
You also said you had a concern O
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regarding the amount and extent of traffic control 2
and how that relates to the analysis.
Is that 3
correct?
4 A.
Yes, sir.
5 O.
Could you please explain that concern 6
for me in a little more detail?
7 A.
Sure.
For instance, at the 8
ntersection of Newbridge Road and Sunrise Highway--
9 Q.
Excuse me.
You are referring to a page 10 in the analysis.
Why don't you point me to that 11 page?
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I 12 A.
Not yet.
'13 Q.
Okay.
14 A.
I am working on it.
15 The figure A-8 on A-11 --
16 Q.
A-117 17 A.
A-11.
This figure and the associated 18 supporting documentation suggests that the traffic 19 southbound on Newbridge Road is not of concern.
20 There is, elsewhere--and I am not sure where at this 21 moment without--well, somewhere in the documentation 22 there is a traffic control plan for this (3_,Y r
COMPUTER AIDED TRANSCRIPTION / keyword index
~24
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1 inters'ection which essentially encourages traffic
'2
. southbound-on'Newbridge Road to turn right on-
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3 Sunrise Highway.
Assuming that takes place, then
.4 the assumption that that tra'ffic doesn't affect the 5
operation is essentially true.
61 I am not sure'that-I would agree at 7
this point that if'there is no traffic control, that 8
traf.fic doesn't interfere with this particular 9
intersection.
10 Q.
Do you anticipate testifying at all on
'11 whether there will'be traffic control or not?
t 12 A'.
No, sir.
6 113 Q.
Are'there any other examples that you i
^ 14.
can give me regarding the amount and extent of t
15 traffic control?
You have Just given me one 16 example.
If that is the total of you-.
concern, that 17 is-fine.
-If there are other examples,-I would like I
18-them, please.
19' A.
There are other locations that have J
20 traffic control suggested.
Whether or not there is 21 or isn't going to be that traffic control. I don't 22 know the answer to that.
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The analysis that I have read 2
essentially says there is not going to be any 3
traffic control, or the analysis as portrayed 4
essentially says that it is not based on any traffic 5
control, yet there is a traffic control assignment 6
list and strategies to be used.
And this particular 7
example raises some concerns.
I can't give you any 8
other examples at this time.
9 Q.
Your concern was whether or not the 10 analysis treated the possible southbound traffic on 11 Newbridge Road crossing Sunrise Highway.
Correct?
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12 A.
Right.
13 Q.
What would be the effect of that 14 southbound traffic, assuming no traffic control?
15 A.
Well, it depends on its nature.
If 16 that southbound traffic is all going south, then 17 essentially it would have very little effect.
If 18 there is a substantial southbound left-turn 19 movement, that southbound left-turn movement 20 conflicts with a heavy northbound movement, and they 21 can't essentially occur simultaneously.
So, 22 depending on the nature of the traffic, there is F
COMPUTER AIDED TRANSCRIPTION / keyword index
~
I 26 Q,)
1 some potential conflict with the other movements.
2 Q.
I see.
3 Wouldn't the southbound traffic also 4
have en effect on traffic going west on Sunrise 5
Highway and going east on Sunrise Highway?
6 A.
No, not in that sense.
And I am not 7
familiar with the signal situation at that 8
intersection so, I am only relying on the 9
documentation.
If there is no left-turn phase 10 southbound--in other words, if there is not a 11 separate arrow southbound on Newbridge Road, then p.-
12 that traffic only moves when the northbound movement 13 moves.
And so, to the extent that it's not larger 14 than the northbound movement, it has no effect on 15 the amount of capacity of that intersection.
But if 16 there is, in fact, a left-turn movement that is 17 signalized, then in fact it would have some impact 18 on that location.
19 So, it depends on a number of things 20 and I have not visited the intersection.
21 Q.
Let me make sure I understand your 22 testimony.
You have given me an example of where v
COMPUTER AIDED TRANSCRIPTION / keyword index
/
g' 27 p.,;
. 's}
~1:
.the itraffic flow along one leg may not have been 4
2 accounted.for'in the analysis.
I am wondering if at 4
3 this time.you have any other examples of other-4 traffic flows in other intersections that may not.
5 have been accounted for.
6 A.
No, sir.
7 Q.
Is-that something you intend to-look'at 8
further?
9 A..
Yes, I would.
10 Q.
Did you discuss this concern with Mr.
11 Lieberman?
f_q
~
.12' A.
Yes, sir.
. 13 Q.
What did he say to.you about it?
~
14 A.
He' felt that that traffic does not 15
. conflict.with the_other traffic.
-16 Q.
Why is that?
Do you understand the 17 basis for his opinion on that?
18.
A.
Well, I didn't discuss it at length, i'.
19-and I w i.1 1 make my own determination by going out in 20' the field.
All I am concerned is what his opinion l'
21 on the matter is, and then I will go from there.
I 22 am not asking him to convince me.
I have got to t-COMPUTER AIDED TRANSCRIPTION / keyword index
i 28 l
v,/
1-convince myself.
2 Q.
I understand that.
What did he tell you, though, about-3 4
that?'
5 A.
He told me that the movement northbound 6
was the one that was controlling the intersection 7
and that the southbound movement did not interfere.
8 Q.
Do you know what he meant by the 9
northbound movement being controlling?
10 A.
Well, this is a very heavy volume, so 11 the green--
,r]
l l
12 Q.
When you say "this is a very heavy LJ 13 volume," what are you referring to?
14 A.
Northbound.
This is--some of it is 15 traffic coming out of the reception centers.
And 16 depending--depending on its extent, if, as I said 17 earlier, this volume is more than this volume 18 (indicating) and as long as this movement doesn't 19 have its own separate signal phase or isn't 20 controlled in some other way, then there is no 21 problem.
22 Q.
You said that if the northbound volume
/~h (v)
COMPUTER AIDED TRANSCRIPTION / keyword index
29 l
(
%,/
1 is greater than the southbound volume, then there is 2
no problem?
3 A.
If the northbound volume is greater 4
than the southbound volume and there isn't a 5
separate signal phase for the southbound left turn, 6
then in.all likelihood there isn't a problem.
7 Q.
Okay.
7 8-A.
Now, there is obviously--if you have 9
the data, it is easier to prove with the data.
In 10 many cases you can go by observation.
Once you go 11 out there and see what the roads are like and the j
(
)
\\/
12 volume of traffic, you may be able to satisfy 13 yourself that that's a reasonable assumption.
14 Q.
Did you discuss with Mr. Lieberman at 15-all the ability of the sites themselves to handle 16 the traffic?
17 A.
No.
18 Q.
You had no discussions with him on that 19 matter?
20 A.
No discussions.
21 Q.
Have you had discussions with anyone 22 other than Mr. Lieberman on that matter?
/"T (v)
COMPUTER AIDED TRANSCRIPTION / keyword index
30-
?,
Q) 1 A.
My attorney.
2:
Q.
Anyone other than your attorney?
3 A.
No, sir.
4 Q.
I think you said that you had a 2
15 discussion with Mr. Lieberman regarding traffic
'6 exiting onto the' Sunrise Highway.
Do you recall-
'7 that?
8 A.
Yes, sir.
9 Q.
And you referred to page 19 of the 10 analysis?
i f.
l'1 A.
Right.
12 Q.
- Could you explain ~a little further-the 14 question you raised and the concerns you had 13 l!.
'14 regarding that question?
L 15 A.
Surely.-
The way this figure.5-1, part 16 B,
is' drawn--
l.
17 Q.
That deals with the Bellmore reception 18' center, right?
i, 19 A.
Deals with the Bellmore reception.
20 The way it's drawn could be interpreted i
21 to suggest that that traffic turning right just i
22 disappears.
COMPUTER AIDED TRANSCRIPTION / keyword index l
A 31 Ql 1
Q.
Which traffic are you referring to now?
2 A.
The traffic exiting the reception 3
center, essentially going north as it turns right to 4
go east, is just drawn as en arrow coming out of the 5
reception center.
6 That traffic does, in fact, come back 7
through the intersection we have Just been 8
discussing in some detail.
So, it is not--you can't 9
Just look at the traffic entering the reception 10 cent'er from Newburgh (sic.) road as being additional 11' traffic on this intersection.
You also have to
/,__\\
C
/
12 consider as additional traffic on this intersection 13 the traffic exiting from Sunrise Highway.
14 O.
I understand that.
You discussed this 15 issue with Mr. Lieberman?
16 A.
Right.
17 Q.
What did he tell you regarding your 18 question?
19 A.
That it is, in fact, accounted for.
20 Q.
Have you gone back to the underlying 21 documents to determine whether it is, in fact, 22 accounted for?
/^T G,'
COMPUTER AIDED TRANSCRIPTION / keyword index
32 h'%)
1 A.
~Not yet.
2 Q.
Do you intend to?
5 A.
Yes, sir.
4 Q.
Do you intend to testify at all on the 5
effect of additional traffic control on the results 6
of this analysis?
7 A.
What do you mean by " additional traffic 8
control"?
9 Q.
Well, more traffic control than is 10 reflected in the results of this analysis.
11 (Pause.)
7-)
f 12 Q.
Let me restate the question.
13 Do you intend to testify at all on the 14 effect of traffic control on the ability of_the 15 reception centers to handle the flow of traffic?
16 A.
I could anticipate that.
I don't have 17 any--I really haven't formulated even a preliminary 18 idea of what my testimony is going to be like.
So, 19 right now my concept of my testimony is a blank 20 sheet of paper.
But I would not rule it out.
I 21 think it's an issue that could very easily be a part 22 of my testimony, p)
-Is._,/
COMPUTER AIDED TRANSCRIPTION / keyword index
33 j
m.
'n I 1
Q.
Have you discussed that issue with Mr.
2 Lieberman at all--that is, the effect of traffic 3
control on capacity or the ability of the roads to 4
handle the traffic?
5 A.
I think only in the extent that I was 6
asking whether or not the analysis did or didn't 7
include traffic control.
8 He also did mention that there was, you 9
know, an unknown as to whether or not--I ouess it's 10 in this case, Nassau County Police were or were not 11 going to participate.
\\'
12 Q.
Did you discuss with Mr. Lieberman at 13 all whether he intends to conduct additional 14 analyses other than what is reflected in KLDTR 1927 15 A.
I didn't ask him that, but he 16 volunteered that there were.
17 Q.
Did he describe the nature of the 18 additional analyses to you?
19 A.
Only in the extent that he was waiting 20 on the new 1985 highway capacity software which 21 would allow better documentation and less likely 22 errors in terms of computations which he had not s-COMPUTER AIDED TRANSCRIPTION / keyword index
sn/
34 m.
v 1
received.
2 Q.
Did he say when he anticipated 3
receiving it?
4 A.
I told him I had mine.
5 O.
Did you offer yours?
6 A.
No, sir.
He was having them Federal 7
Express it to him.
8 Q.
Do you intend to use your software at 9
all in order to conduct further analyses of this 10 document or to prepare your testimony?
11 A.
I hope not, but it's possible that I fm,
( )
12 would, in fact, run some of the analysis on there.
13 I would not do the analysis manually.
I decided 14 that a long time ago.
15 O.
Do you have any particular analyses in 0
16 mind or you are just not ruling out the possibility?
17 A.
I think at some point the numbers that 18 are involved in some of these intersections, one 19 needs to verify.
The problem is--the problem I 20 have, if they are going do redo it, then spending 21 time analyzing what they already have done doesn't 22 really make a lot of sense, because even if I find O
COMPUTER AIDED TRANSCRIPTION / keyword index
U 35 L
I
%,,1 i
something wrong, they can come back and say, "Well, 2
we fixed it."
So, that's why I would not 3
necessarily anticipate doing a lot of work on that 4
line.
5 But the problem I foresee here is we 6
are shooting at a moving target here, which makes 7
life more complicated than I'd like it to be.
8 Q.
Are there any other questions or 9
concerns you have regarding the KLD analysis?
10 AS I think you already asked that 11 question.
I hope not.
12 Q.
Did you receive the KLD document from 13 your counsel?
14 A.
No.
I received it from Falk Kantor at 15 NRC.
16 Q.
I believe you said earlier that you 17 felt generally that the methodology as applied was 18 correct.
Is that a fair statement of your 19 testimony?
20 A.
Yes, sir.
21 Q.
Can you describe briefly the 22 methodology that was used in the analysis and why COMPUTER AIDED TRANSCRIPTION / keyword index
Ns/'
t 36 i
')
1 you believe it is generally appropriate?
2 A.
Essentially, they determined the amount
~
3 of traffic that"s coming from the emergency planning 4
zone--I take that--they have identified alternative 5
volumes from the EPZ that might possibly come to 6
this site.
Essentially, a range of conditions.
So, 7
that represents one aspect of the traffic demand, 8
those people that want to be at the reception 9
centers.
10 They identified the routes to get 11 there.
I guess I did ask Ed how, on what basis it
)
's /
12 was assumed that people would use those routes, and 13 he indicated through the public information 14 brochures.
15 So, they established the traffic demand 16 from the EPZ, how it's going to get there, and they 17 have also established what other traffic might be in 18 the area through their traffic counting program.
19 Then they have done an analysis of the capacity of i
i 20 the intersections to see how they will perform.
And 21 that's essentially going to tell you whether or not l
22 you have a traffic problem in a vicinity of the n
_/
l COMPUTER AIDED TRANSCRIPTION / keyword index
37 1
reception centers.
2 So, the only issues became, then, 3
things like what is the volume of traffic?
Is it 4
100 percent of the EPZ population, which seems 5
unreasonable, or is it going to be a lesser amount?
6 And what is the likely capacity of the system?
7 So, it's really a straight--the 8
analysis is straightforward.
We need to be sure 9
that the analysis has been done, the details have 10 been properly done based on some reasonable 11 assumptions.
12 Q.
Now, the volume of traffic, you will 13 agree, is one of the factors which determines 14 whether or not these sites can handle the influx of 15 traffic in twelve hours.
Correct?
16 A.
Yes, I believe that's true.
I don't 17 purport to know too much about the twelve-hour basis 18 that is being--has been bandied around in the 19 various documents.
20 Q.
Putting aside the twelve-hour question, 21 the volume of traffic, or to put it another way, the 22 demand on available capacity is one of the factors m
COMPUTER AIDED TRANSCRIPTION / keyword index
38'
+
5
,r"N.
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whether to be considered when determining
~ '
'1 that has 2
Lor not.the roads can' handle that-volume.
Right?
3
'A.
_Right.
4 O.
Do you have any opinions at this time 5
on the amount of background traffic--that.is, 6
?nonevacuating. traffic--that evacuees might' encounter
'7 lin the' event of an emergency?:
~8 A.
.That's n' tough one.
I don't--I don't 9
have en easy answer to thetione.
10 Q.
Is that something you intend to think 11 about further?.
,R t
):
3%/.
12-A.
Yes.
I would need to think about that 1
t 13 further.
14 Q.
Do-you anticipate that you will be 15 offering an opinionJat' trial on the amount of 16 background traffic that' evacuees might encounter?
17
.A.
I would probably venture that I would 18 offer en opinion; yes.
' 19' O.
'But at this time you have no idea what-f.'
120-that. opinion will be?
21 A.
No.
22-Q.
Now, this analysis does not take into sm I
h~
N./
COMPUTER AIDED TRANSCRIPTION / keyword index
.. _ -, ~. _.,
39 1
account any additional demand from what we have in 2
the past referred to as the shadow phenomenon--that I
evacu q 3
is, people ava4butir.g-from outside the EPZ even 4
though not advised to do so.
Isn't that correct?
5 A.
I am not sure how that relates to this.
6 I find that portion of it somewhat puzzling.
7 O.
I'm sorry.
I don't understand your 8
answer.
9 9
A.
Why would these people in the 10 evacuation shadow be coming to the reception 11 centers?
x
(
12 Q.
Well, without looking at their motives, 13 does this analysis take into account any additional 14 demand from people outside the EPZ who may evacuate 15 and be heading west even though they have not been 16 advised to evacuate?
17 A.
I am not familiar with any inclusion of 18 any shadow traffic in the analysis.
19 Q.
Do you intend to offer any testimony on 20 the likelihood of traffic demand increasing as a 21 result of people outside the EPZ evacuating?
22 A.
I really don't know.
At this point I x
COMPUTER AIDED TRANSCRIPTION / keyword index
40 l
i haven't anticipated that, but I wouldn't rule it 2
out.
3 Q.
Do you anticipate that you might 4
conduct a sensitivity analysis to determine how such 5
excess demand might affect the ability of the roads 6
to handle the traffic?
7 A.
I don't anticipate doing that; no.
8 Q.
In your opinion, should the KLD 9
analysis consider traffic from outside the EPZ 10 generated by people who are evacuating even though 11 not advised to do so?
12 A.
Well, you have to do an analysis that 13 is reaconable for the situation.
So, if one 14 believed that there was a need do that, then one 15 would have to do it.
16 O.
Do you have any feelings right now as 17 to whether or not there is a need to do that?
18 A.
I think I offered an opinion earlier 19 that I didn't really see how the shadow phenomenon 20 fits in here.
But like I said, I haven't given it a 21 whole lot of thought.
22 Q.
When--
P COMPUTER AIDED TRANSCRIPTION / keyword index
Y 41 1
A.
Or any thought.
2 Q.
When we talk about the shadow 3
phenomenon, just to make sure we are talking about 4
the same thing, is it your understanding that that 5
term describes people evacuating even though not 6
advised to do so?
7 A.
Yes, sir.
8 Q.
Is it reasonable to assume that if some 9
people did evacuate even though not advised to do 10 so, that they would head west?
11 A.
I think this has all been covered.
We 12 are getting back into the whole issue of evacuation 13 and going all the way back to square one.
I think 14 this issue of evacuation and shadow phenomenon is a 15 very complicated one and has been previously 16 examined in great detail.
And I think the answers 17 that have been previously provided apply in the same 18 case again.
19 Q.
Let me ask you this.
Assuming there 20 was shadow traffic and it did head west, isn't it 21 possible that it could take up some of the available 22 capacity on the routes going to the reception
,- m COMPUTER AIDED TRANSCRIPTION / keyword index
W 42 g%.
\\, )
1'
-centers?'
2-A.
That '..s possible.. yes.
But not-3~
- necessarily'the ones we are studying.in great 4
' detail.-but others.
You can essentially take this analysis 5
6 and back it all thelWay back to-their. homes, if you-7 want to.go far enough back.,
8' O.
Do you have_any opinion right now'es to.
9 whether.or not the-routes assigned to evacuees.in thefmajor routes--heading west 10 the KLDianalysis are 11 out of'the EPZ?.
pg
.f I
\\s' A.
Yes.
I believe they are the major 12 13 routes.
And I guess I would argue the issue of the 14 shadow phenomenon has already been addressed'.as part.
15 of the evacuation of-the EPZ, that we are looking at~
16 a much more narrowly defined issue here, which is 17
'traf.fic in the more immediate vicinity of the 18 reception centers.
And in that context, I don't.see 19 that the shadow traffic affects this, unless we are 20 also going to add another assumption that they are 21 also going to know where the reception centers are 22 and going to want to use them.
O COMPUTER AIDED TRANSCRIPTION / keyword index
V 43 1
Q.
Is it your opinion that they wouldn't 2
want to use them, or do you not have an opinion on 3
that?
4 A.
I essentially have no reason to suspect 5
at this time that they'd want to use them or even 6
know that they exist.
7 Q.
Won't they know they exist from public 8
information disseminated at the time of the 9
accident?
10 A.
I don't know the answer to that.
11 Q.
Putting aside whether or not they go to 12 the reception centers--that is, shadow 13 evacuees--isn't it possible that they could still 14 take up available capacity on the routes leading to 15 those reception centers, thereby causing delays for 16 those evacuees trying to get to the reception l
17 centers?
18 A.
The answer is sort of yes and no.
I 19 mean, yes, at some point that traffic affects 20 evacuating traffic.
But I think at this point I 21 would argue that that's been accounted for in the 22 issue of what traffic should be accounted for in
,~,
f COMPUTER AIDED TRANSCRIPTION / keyword index
. w -.
44 s
P f'%.
' (%) '
l 1
-doing the' evacuation 1 time-estimates for the sites.
10-2!
So, when you'get in close proximity to 3-th'e reception centers, then at that pointJwe are 4
Just l'ooking at the' issue of whether or not the 5:
local street system can accommodate that traffic.
6 I guess-to summarize,'What I am trying 7
to say is that if that traffic affects evacuation, 8
it affects'itlin a general, not--it does not affect 9
the receptionEconters per se.
10 Q.
.In your drive along the roads tomorrow,-
11 do you. intend to look at whether or not there are cj 3) 1
~
12 any, additional intersections which should be studied
- s~<
13 that haven't been studied yet?
14 A.
Yes, in the sense that if I think there 15
.is a problem they haven't-looked at, I-will r
L 16 certainly identify it.
i 17 Q.
You have no way of knowing now whether 18 or not all intersections which might pose a problem 19 have been analyzed in the KLD report.
Correct?
t-i 20 A.
That's correct.
-That is the reason for I!-
21 visiting the site.
If one could rely on the 22 document, I'd Just read it.
l I
I l-
-COMPUTER AIDED TRANSCRIPTION / keyword index
t' 45 i
- (% ;
,h,
~
1:
-Q.
Do you-intend to look.at any roadway b2:
links,'as' opposed to intersections,-'to determine 3'
whether.they might.-be a constraining. factor _with I
. '4
-respectEto roadway capacity?
5
-A.-
Sure.
-6'
,' Q.
.Now, the-KLD '.- analy si s ' doe sn' t look at; 7-
'any ~ roadway l' i n k s as opposed to intersections.
ic
'8 Correct?
I L9
-A '.
It doesn't' call'out any problem
'10 locations that are links, and in all likelihood lih there are not any problems.
Intersections are the i YN.
12 fundamental problem.
Links become problems when
.13 there ~is-less lanes between-intersections than there
'14 are at intersections.
And that,is not generally'the 15' case.
,So, the absence of any' analysis: on links is
'16 not, in and of itself, suspicious.
1 17 Q.
.But you will be looking to see'whether r
18-or not links should be' looked at more closely?
19.
A.
Yes.
I drive with my eyes open.
20 Q.
I believe you said that you discussed I
21 the route assignments with somebody.
Was it with i
22 Mr. Lieberman?
d COMPUTER AIDED TRANSCRIPTION / keyword index
46
- ~.
' s.
1 A.
Right.
2 Q.
What was the purpose of discussing the 3
route assignments with him?
4 A.
Get some feel for their logic.
If you, 5
for instance--if you look at page OPIP 4.2.3, page 6
16 of 29, traffic on Southern State parkway heading the map, such as 7
west passes other roadways shown on 8
Newburgh (Sic) Road, which are alternative routes 9
for cetting there, and instead goes essentially 10 beyond-the Bellmore operations center, uses 11 Meadowbrook Parkway southbound and then returns via j-t
)
12 Sunrise Highway.
And not knowing anything about the 13 14 site, one could argue that there would be some 15 advantage to using Newbridge Road--
16 Q.
Or Merrick Avenue?
17 A.
Well, Merrick would not--Merrick is 18 beyond, so that doesn't necessarily look as an 19 alternative.
20 Q.
Did you discuss this particular 21 routeing scheme with Mr. Lieberman?
22 A.
Yes, sir.
tV' COMPUTER AIDED TRANSCRIPTION / keyword index
-47 t-
~,i 1
O.
What did he tell you about the logic 2
behind routing traffic to the Meadowbrook. State 3
Parkway?
4.
A.
That it was two-fold.
One, that people 5
would not be familiar with the area so, therefore 6
they were: keeping them on the major highways, which 7-they would be more familiar with, and'that Newbridge 8
Road is essentially a two-lane, low-capacity road.
9 O.
Do you have any understanding as to how 10 traffic would be routed as described on page 16 of 11 OPIP 4.2.37 t
/
12 A.
Routed in what sense?
13 Q.
Directed to follow those arrows.
14 A.
Through the public information program.
15 Q.
Do you have any understanding of l
16 exactly how that public information would be 17 disseminated?
18 A.
No, sir.
19 Q.
Is it your understanding it would be 20 disseminated before an accident or at the time of an 21 accident?
22 A.
How can I answer that if I have no
/
')
(/
COMPUTER AIDED TRANSCRIPTION / keyword index
40.
, m
}
v 1.
understanding?
2 Q.
Traffic from various subzones of the 3
EPZ is routed along various paths to the three
~
4 reception centers.
Correct?
5 A.
Yes, sir.
6 Q.
Do you have an opinion at this time on 7
what the effect would be if people did not follow 8
the routes that were assigned to them in the KLD 9
analysis?
10 A.
I could see that in certain cases there 11 could be some potential problems.
J 12 O.
Problems being delays or congestion?
13 A.
Right.
There could be-some additional 14 delays or congestion.
15 O.
You said "in certain cases."
Are you 16 talking about with respect to certain reception 17 centers, or what?
18 A.
I am only saying it in the sense that 19 it could or couldn't happen.
It would depend on the 20 specifics.
It's not based on any particular 21 locations.
22 Q.
Do you believe that you will be O) t%/
COMPUTER AID ~D TRANSCRIPTION / keyword index
.~
49
. /~L t
1 N _j.
1 offering testimony on the issue of whether people i t'-
2 will or will not follow the rout'es assigned to them?
-3 A.
Probably-not.
4
- Q.
Do you consider yourself an expert-on 5
that subject?
6-
"A.
On that subject?
Do you want-to tell-7 me what that subject is?
8'
.Q.
Whetherfor not people will follow the 9
' routes assigned to them.
-10 A.
-An expert in, perhaps, certain aspects
-11 of it,'in terms of traffic control-signs and other
- [:A/).
12
' things and their-' ability to. negotiate the roadway
'13 network, but not as-an expert in public information 14 or--
15 O.
So you don't consider yourself an 16 expert on whether people will respond appropriately-17 to public information disseminated by.
18 broadcasts, for instance?
19 A.
Not specifically, no.
20 Q.
Do you have--
21 A.
Not as an expert, anyway.
I may offer 22 some opinions.
O COMPUTER AIDED TRANSCRIPTION / keyword index
50
~J 1
O.
You may offer'some opinions in your 2
' testimony as other than an expert?
3 A.
Well, as being familiar with the 4
literature and what's going on and the like.
And we 5.
know people, you know, despite everybody's
'6 inclination otherwise, generally respond quite well 7
.to evacuations.
I am not ignorant of the issue.
8 Q.
Do you have any other understanding of 9
signing that would be present in the event of an 10 evacuation?
11 A.
I'have no information on that at this rh
)
\\~/
12 time.
13 Q.
Is that something you intend-to look 14 into?
15 A.
I'd want to know how they are going to 16 accomplish getting the people there.
And they are 17 doing it through maps and other information, that's 18 one way.
Signing would be another way.
19 Q.
People are not only assigned to paths 20 but they are also assigned to particular reception 21 centers at the end of those paths.
Correct?
22 A.
Yes, sir.
D
/
i N._/
i COMPUTER AIDED TRANSCRIPTION / keyword index
51
(-
1 Q.
Do you have any opinion as to what the 2
' result would be if people went to reception centers 3
other than those-that they-were assigned to?
4 A.
That's pretty complicated.
It would 5
' depend on a whole host of assumptions on how many 6
people are really evacuating.
For. instance, if only 7
20 percent are evacuating and the sites can 8
accommodate 100 percent, 20 percent times three is 9
60 percent.
Any site could accommodate the traffic.
10 So, it's, you know...
11 Q.
But--
,._( )
N' 12 A.
If there was 100 percent going to all 13 the ~ sites and they don't use one, and 200 percent 14 goes to a site, I would be concerned, yes.
15 In other words, if they had double the 16 demand relative to what's called 100 percent of the 17 allocation.
18 Q.
Rather than looking at the extreme 19 situation of 100 percent of the population going to 20 one reception center, do you intend to look at the 21 possibility that some smaller percent might go to a 22 reception center to which they have not been O
I i
V COMPUTER AIDED TRANSCRIPTION / keyword index
52 x
Q) 1 assigned?
2 A.
No.
3 Q.
Do you have an opinion on what the 4'
results would be if that occurred?
5 A.
My opinion is that substantially less 6
than 100 percent of the population is going to any 7
one of the sites and that, in that case, some of the 8
issues of the specific routing are not as important 9
as they would be under other assumptions.
10 Q.
I'm sorry.
I am not quite sure I 11 understand.
O I
/
\\/
12 A.
If you only have to plan for 20 percent 13 of the traffic, the magnitude of the problem is a 14 lot less than the magnitude of the problem if you 15 have to plan for 100 percent, and at a certain point 16 it really doesn't matter, the routing of the traffic 17 that gets there.
In fact, the more dispersed the 18 routings, the less the problem.
And the reason the 19 reception centers need to be looked at in detail is 20 that 's where everybody finally arrives and all the 21 traffic then is all concentrated.
It is when 22 traffic is concentrated that it's a problem, not O
COMPUTER AIDED TRANSCRIPTION / keyword index
53
('S w/
1 when it is dispersed.
2 Q.
Let me back up a second.
You mentiond 3
a 20 percent figure.
Could you explain why you 4
brought that figure up?
5 A.
I think it's in the documents as being 6
FEMA's number r# reception centers.
I have not seen 7
that document, so I am only using that number 8
secondhand.
9 Q.
Is it your opinion that there is a 10 regulation of some sort that says that one need only 11 plan for 20 percent of the population arriving at
,,)
(!
k-12 the reception cent for monitoring?
W 13 A.
I do believe there is a regulation.
I 6
14 believe there is some guidance issued by FEMA.
15 Q.
Is that for monitoring or sheltering?
16 A.
I don't know.
17 Q.
There is a difference between the two 18 functions.
Correct?
19 A.
Monitoring and sheltering--sheltering, 20 I am not sure what you are referring to by 12 21 sheltering.
You are talking about stnying in your 22 home?
O
(/
COMPUTER AIDED TRANSCRIPTION / keyword index
d 54 i
\\
A,
,/
j i
O.
No.
I am talking about people going to 2
a place for shelters who have evacuated.
3 A.
Like I said, I don't pretend to be very 4
knowledgeable on that aspect.
My area of expertise 5
is traffic and transportation.
So, I don't know 6
What the 20 percent applies to.
7 O.
In your analysis or in your testimony, 8
do you intend to restrict yourself to looking at the 9
case where 20 percent of the EPZ population goes to 10 the reception centers?
11 A.
No.
g]
t
12 O.
Would you look at a larger potential 13 evacuation population percentage going to the 14 reception centers?
15 A.
I am going to do my analysis with, 16 hopefully, some input from others.
17 Q.
Which others?
18 A.
I don't know.
19 O.
So, you would look to others to 20 determine what planning basis should be used to 21 determine how many people should be planned for?
22 A.
What do you mean " planning basis" and
/O
(>
COMPUTER AIDED TRANSCRIPTION / keyword index i
55
(
)
N/
1
" people planned for"?
2-Q.
Let me see if I can rephrase it.
3 You would look to others with respect 4
to the amount of demand which might be placed on the 5
reception centers?
6 A.
Yes.
7 O.
And at this time you don't know who 8
those others are?
9 A.
Yes.
I don't know who the others are.
10 (Brief recess.)
11 O.
Dr. Urbanik, do you intend to rely on D.
'\\ /)
12 any specific published material to prepare your 13 testimony?
14 A.
Essentially, I think I indicated--will 15 indicate that Nureg 0654 is a possibility, the KLD 16 report which I have mentioned.
There are some 17 documents on my resuma that are candidates, and 18 anything that has to do with general traffic and 19 transportation literature, such as the Highway 20 Capacity Manual.
21 Q.
Can you tell me how Nureg 0654 pertains 22 to the issue of traffic going to the reception
[
j v
COMPUTER AIDED TRANSCRIPTION / keyword index
W 56' yy..
\\
I'?s
' centers?
1' f2 A.
'Hardly at-all..
l3 0.
Can you tell me at this' time how you 4
intend'to rely on~it?
5 A.
Never canJtell.
Read between the 6
lines.
I. guess.
~7 At this point. I don't know.
8 Q.
'Can you-tell me what publications of 9
your own you may rely on--well, before we do that,
- 10 let me:show-you a document that purports to be your-11.
curriculum vitae.
I ask you if-you recognize that?
k' 12 A.
You will let me read it?
13 Q.
Sure.
14 A.
Looks like a reasonable facsimile.
I' 15 have lots of different versions, too, so you have 16 to...
17 MR. BACHMANN:
For the record, that was 13 the one that was provided to the parties on Monday 19 from our supplemental response to the 20 interrogatories.
21 MR. McMURRAY:
Let's mark this as 22 Urbanik Exhibit 1.
This is the curriculum vitae.
O COMPUTER AIDED TRANSCRIPTION / keyword index
t 57
-,e~
(
)'
1 (Urbanik Exhibit No. 1 was 2
so marked for identification.)
3 Q.
Looking at Exhibit 1,
Dr. Urbanik, is 4
this one version of your curriculum vitae?-
1 5
A.
Yes, sir.
6 Q.
Is it accurate?
7 A.
To the best of my knowledge.
They 8
invariably seem to have typographical errors that 9
are glaring, after the fact, but...
10 O.
Other than typographical errors, are 11 there any additions or corrections you would like to O
- t
/
\\~s' 12 make to that exhibit at this time?
13 A.
I don't believe so.
14 Q.
Looking at that exhibit, are there any
.15 publications of your own that you intend to' rely on 16 in your testimony?
17 A.
I don't have any specific testimony 18 that I have prepared, so it makes it kind of hard to 19 say which ones I am going to rely on.
I wouldn't 20 want to rule anything out, but I don't have any 21 specific ones.
Obviously, those that relate to 22 evacuation planning that would be general g"N LY COMPUTER AIDED TRANSCRIPTION / keyword index
.50 A
_' ;i" Q
.1 candidates.
-2 Q.
Do any of your publications deal with 3
' reception centers?-
4 A.
No, sir.
~5
'Q.
Do any of your publications deal with-6-
analogous' situations--that 'is, 'e'vacuees going to a 7
particular place outside the EPZ7 8
A.
Not specifically, no.
By. definition, 9
peop'le evacuating from EPZ's are going.to places 10 outside the EPZ.
11 Q.
Do.any~ of your publications, though,.
\\/
12 deal with their travel to a particular point, such 13 as a reception center?
14 A.
No, sir.
15 Q.
While you haven't yet formulated your
.16 testimony, can you point me to any particular 17 publications of yours which are pertinent enough to 18 the issues at hand that you would consider including 19 them in your testimony?
20 A.
It's my understanding that I will be 21 responding to testimony of others.
So, I don't 22 anticipate, but I certainly don't want to limit any t
a COMPUTER AIDED TRANSCRIPTION / keyword index
.r-59-
, m.
s 13 1
of them.
So, I don't have...
2 The only one that I conceivably could
-3 see at this point would be the first one under 4
" Traffic Engineering" on page four, " Understanding Q<A 5
-for-ene f1ow."
6 MR. McMURRAY:
At this time, Mr.
7 Bachmann, I would like to request a copy of that 8
publication.
9 THE WITNESS:
No problem.
You don't 10 set ITE' Journal?
11 MR. McMURRAY:
Not at home.
Probably j3 t
l
\\/
12 at the office.
13 Q.
Do you intend to review the issue of 14 whether the exits at the reception sites are 15 sufficient to handle the outflow of traffic?
16 A.
I would certainly consider that an 17 important related issue.
18 Q.
You would agree, wouldn't you, that if 19 the traffic can't leave the sites at the rate at 20 which it's entering, that that could cause a 21 problem?
22 A.
Yes, sir, p(v i
COMPUTER AIDED TRANSCRIPTION / keyword index
60
, ~.
%~J 1
Q.
Is that something you are going to look 2
at in your drive tomorrow?
3 A.
I would think so, yes.
4 Q.
By the way, have you prepared any 5
reports or other written material regarding the work 6
you have done to date on this issue?
7 A.
No, sir.
8 Q.
Do you intend to prepare any report or I
9 other written materials?
i 10 A.
Just testimony would be the only thing' 11 I would anticipate preparing.
-s
/
'n 12 Q.
At this time, Dr. Urbanik, I would like 13 to refer you to the KLD study, which is headed 14 "KLDTR-192 "and has been previously identified as 15 Lieberman Exhibit Number 1.
Let me refer you to 16 page 15.
17 On page 15, in the middle of that page, 18 there are a number of procedural steps set forth 19 which were used to conduct the analysis.
Do you see 20 that?
21 A.
Yes, sir.
22 Q.
Do you see, under stop two, it says
[/
'u COMPUTER AIDED TRANSCRIPTION / keyword index
61
)
1
" Calculate the mean hourly background volume on the
'~'
l
\\
2 approaches to key intersections"?
3 A.
Right.
4 Q.
Do you noree with the approach taken in 5
this analysis of using mean hourly background 6
volume?
7 A.
I think you can do the analysis this 8
way, yes.
9 Q.
Well, there seemed to be some hesitance 10 in your voice.
Do you think'it might also be 11 reasonable to look at higher background volumes,
(/~)
12 such as peak background volume?
13 A.
Well, you could alternatively analyze 14 coch hour, which would include doing the peak hour.
15 But you can't do the analysis just on peak hour.
[
16 Q.
If you were doing this analysis, would 17 you look at each hour?
18 A.
I guess it would depend how big a 19 budget I had.
I don't--
20 Q.
Let's assume you were going to be using 21 your software.
22 A.
I guess I'd want to give it more than o COMPUTER AIDED TRANSCRIPTION / keyword index
62
(~
i few seconds of thought to answer that.
Obviously, 2
doing it manually would make doing it hourly more 3
difficult and, therefore, the availability to 4
computerize the analysis obviously allows you to do 5
more analysis.
But one has to be careful to not 6
presume that because you have done more detailed 7
onelysis, that you've got a better answer.
8 Q.
Let me ask you this.
Is it possible used rather than mean 9
that if hourly volumes are 10 hourly volumes, that the results of the analysis could be different?
/"T 11
/
12 A.
I don't think so in the context that wo is are analyzing a problem.
14 Q.
Why is that?
15 A.
Because essentially we have a typical 16 evacuation time frame that we are looking at.
We 17 are not looking at analyzing the people.
We are la looking at, over a period of time, do we have enough 19 capacity.
If we became overloaded in one hour, that 2D traffic is delayed, but it then waits until the next 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> and that doesn't necessarily affect the amount 22 of time that it takes to complete the whole process.
O COMPUTER AIDED TRANSCRIPTION / keyword index
63 4
1 It just means that somebody waited longer than they 2
would have liked to.
3.
Q.
Are you saying that the results 4
necessarily wouldn't be different or that they might 5
not be different?
6 A.
Well, you have to look at all the 7
details that go into the analysis.
It could--under 8
certain circumstances, you could get a different 9
answer using hour-by-hour numbers than using a mean 10 number.
I think that's possible.
11 Q.
Let me refer you to<page 17 of this I'
12 analysis.
This is table 5-1.
Do you see that?
13 A.
Yes, sir.
14 Q.
Do you see, in the first table at the 15 top, the last column in headed " phase"?
16 A.
Right.
17 Q.
Under that are some letters?
18 A.
Right.
19 c.
Do you have an understanding of what 20 the term " phase" means?
21 A.
Yes, sir.
22 Q.
What is it?
COMPUTER AIDED TRANSCRIPTION / keyword index
64 l
)
[
)
1 A.
Well, it is a traffic engineering' term l'
14 2
to determine which movements are taking place at a l
3 traffic signal.
r 4
Q.
Sorry.
Go ahead.
S
'A.
And how many separate movements are I
6 accommodated.
The-fact that there is a "C" phase 7
there indicates to me that there is a left-turn 8
phase.
F 9
Q.
Do you intend to do any independent 10 analysis of whether or not the greenEtime reflected 11 in this analysis is accurate?
i
[d 12 A.
I am going to visit the sites and look is at the types of control and get some indication of 14
.how it's operatings yes.
But I don't--I wouldn't l
15 call it an independent analysis.
16 Q.
Do you intend to time any of the signal 17 lights?
18 A.
That's definitely a possibility.
19 Q.
Looking down at the last part of that 20 table, there is a calculation that says 21
" CAP =(SF)x(G/C)xE-sub-c."
Do you see that?
22 A.
Yes, sir.
O COMPUTER AIDED TRANSCRIPTION / keyword index i
F, 65
/
y j
1 Q.
Do you have an understanding of what s
2 "E-sub-c" is?
3 A.
Yes, sir.
4 Q.
What is it?
5 A.
It is in the notes there.
E-sub-c is 6
the efficiency of the traffic signal.
It equals 7
C-effective over C; where C-effective is the effect 8
of usable green time over one cycle duration C.
9 I did ask Ed Lieberman about this.
10 Q.
What was your question to him?
11 A.
Why he essentially defined his own term n
(
)
12 E-sub-c to replace little-G and put' big-G in the U
13 equation.
14 How deep do you want to go?
15 Q.
For us laymen, I would like a more 16 detailed explanation but in terms, hopefully, that a 17 layman could understand.
18 A.
I will give it a shot.
19 He didn't--to put it in a big picture, 20 he didn't give me an explanation that totally--he 21 more or less said that's the way he did it, which 22 wasn't totally satisfying, other than it was v}
COMPUTER AIDED TRANSCRIPTION / keyword index
66
?
)
i convenient to redefine some terms.
2 The highway capacity manual has a 3
slightly'different form of thst, where essentially 4
you don't use the actual green time on the signal, 5
which is represented by big-G, but you use the 6
effective green time, which is little-g.
But they 7
are interreinted and there are lots of different 8
formulas on how you could compute that.
That's 9
probably guessing why he used that, just to simplify 10 the process.
11 All he's doing is putting in a
[)
12 multiplier to convert big-G to little-g, which comes
\\_/
13 up with an effective green time.
14 Q.
Do you have en opinion on whether or 15 not Mr. Lieberman's approach here complies with the 16 Highway Capacity Manual?
17 A.
Complies?.
I think he's differed 18 somewhat from the Highway Capacity Manual, not 19 necessarily in a way that has any practical 20 significance in the context that we are evaluating 21 in this--unfortunately, this highway capacity 22 procedure was put together by another fellow at
/3 g,Y COMPUTER AIDED TRANSCRIPTION / keyword index
67 j
1 Texas A&M, an academic type.
And I think sometimes 2
we have.a little more precision than accuracy in the 3
numbers.
So, you're arguing over the precision and 4
I would say we've got to look at the accuracy of the 5
number.
6 So, using the Highway Capacity Manual 7
is not the only way to do it.
8 Q.
Do you have an opinion on whether or 9
not the results would be different if the 10 calculation used was the one in the Highway Capacity 11 Manual rather than the one used by Mr. Lieberman?
,a
(
)
12 A.
I haven't done that yet, but I wouldn't L/
13 be surprised if there would be non-significant 14 differences.
15 O.
Do you intend to look at that?
16 A.
Yes.
17 Q.
On page 18 of the document, there are a 18 number of cases which are looked at in the analysis 19 with various assumptions being changed.
Do you see 20 that?
21 A.
Yes, sir.
22 Q.
Do you intend to rerun those cases I
t P's N)
?
COMPUTER AIDED TRANSCRIPTION / keyword index
-68 E
y m;.
( )_:
in using'your' software?
~
2 A..
No.
- 3-Q.
Do'you' intend to'look at any other 41 cases?
-5.
'A.
N o..
(F Let me--I think there ere other cases i
7 that ~ are--I guess I am putting-that in a context of.
8 looking at'this document.
I don't want to 9
presuppose looking at anything at any time that 10 would be relevant to traffic operations.
It's notia
.11 blinders kind of a process.
Someone may make some r~s f
)
. 12.'
testimony about control versus no control and then I'
13 will look at the control options.
So,-I don't have
~14 any plans to construct any of my own scenarios, but 15 I.wouldn't say that I'd want to be limited to what's 16-on this sheet of paper as things I will look at.
,15 17=
0.
Appendix C of the. document sets out a 18 number of traffic control strategies.
Have you 19 reviewed any of them in detail?
20 A.
No, sir.
21 Q.
Do you have any opinion on whether or 22 not they are reasonable traffic control procedures?
O COMPUTER AIDED TRANSCRIPTION / keyword index
69 f M..
A.
Not at this time.
i\\Q.
1 2
Q.
Is that something you intend to look 3
at?
4 A.
I am.not sure.
I would-imagine that I 5
will.
.But if.there is no--if the final thing comes 6.
down to that we areinot going to have traffic 7
control, then-it is' kind of a moot question on 8-whether we need to analyze'it.
9 Q.
Are there any other instances in the
~ 10 report, in the analysis, that you can think of_where.
11 Mr. Lieberman or KLD deviated from the Highway
' rs.
Manual,.other.than.the instance'we referred 12 Capacity
(' % ))
13 to a few minutes ago on page 177 5 4 --
A.
I am not aware of any, but I wouldn't 15 preclude that he has deviated from it.
16-
.Q.
Do you know what I mean by the term
-17
" delay analysis" in the context of intersection 18 Lcapacity?
19 A.
I think I understand it.
I. don't know 20 if you understand it.
21 Q.
You are probably right there.
Why 22-don't you educate me, then, and tell me what " delay O
COMPUTER AIDED TRANSCRIPTION / keyword index
70
!(.,) ~
1 analysis" is.
2 A.
Well, the new Highway Capacity Manual 3
takes a different approach to coming up with level 4-of service at intersections, and it uses delay as 5
thermeasure of effectiveness for coming up with 6
level of service.
In the context we.are talking 7
about, that's largely unimportant.
It's not really 8
an' issue.
9 Q.
Why is that?
10 A.
We are not trying to quantify the delay 11 or leveloof service.
We are trying to determine
,- 3
(
)
12 whether or not we can get the people in or out of x;
13 the site within twelve hours.
Evacuation traffic is 14 almost, by definition, a real poor level of service.
15 And we have no reason to want to quantify it at this 16 point.
17 Q.
Have you read Mr. Lieberman's 18 deposition?
19 A.
No, sir.
20 Q.
Do you intend to conduct any further 21 analysis of the paths to which the traffic is 22 assigned to determine whether or not those paths are
[L-}
COMPUTER AIDED TRANSCRIPTION / keyword index
71
- x._)
1 reasonable, or whether additional paths should be 2
added?
That is a compound question.
If you want me 3
to break it up, I will.
4 A.
I don't have any intent to be spending 5
much time looking at alternate paths, but that would 6
not preclude that if at some point in the process it 7
was determined that alternatives ought to be looked 8
at, that some recommendation wouldn't be made.
I 9
mean, if the proposed plan has problems in it, then 10 there is good reason to look at alternatives, isn't 11 there?
f~,
l 12 Q.
The intersections that were reviewed by
.v) 13 Mr. Lieberman had actuated signal controls.
Is that 14 your understanding?
15 A.
It's my understanding that they are 16 principally of that type.
I don't think he alleged 17 that they were all of that type.
18 Q.
Does the presence or absence of 19 actuated signal control affect the results of this 20 analysis at all?
21 A.
To some extent, yes.
22 Q.
In what way?
h
%J COMPUTER AIDED TRANSCRIPTION / keyword index
72 s_,,'
1 A.
Well, you are taking credit for the 2
ability of the signal to respond to traffic.
If the 3
signal cannot respond to traffic, then you need to 4
use the signal timings that would be appropriate for 5
the type-of operation that you were analyzing, or 6
have traffic control to override it.
That's why all 7
these issues kind of run into each other.
8 Q.
Are you aware that people without cars 9
are going to be bussed from various transfer points 10 to the Hicksville reception center?
11 A.
I believe that's my understanding.
,(/)
12 They are all going to just one.
13 Q.
Right.
14 Do you have any opinion regarding 15 whether or not those buses will place an extra 16 demand on the availability capacity?
17 A.
They place some additional demand and 18 need to be accounted for, but in terms of being a 19 large impact, I don't think that they do.
I would 20 be surprised if they had a large impact, but I don't 21 think you can Just summarily dismiss them.
22 Q.
Is that something you intend to look jq l
)
%/
COMPUTER AIDED TRANSCRIPTION / keyword index
73 7
s.,
(_)
1
'at?
2 A.
I intend to make sure that that's 3
-properly considered, yes.
4' O.
Do you know whether that has been 5
considered in Mr. Lieberman's analysis?
6 A.
I sure don't.
7 Q.
Other than your phone call with Mr.
8 Lieberman yesterday.or the day before, have you had 9
any other discussions with Mr. Lieberman about his 10 study?
r 11 A.
No, sir.
A,[/)
12 MR. McMURRAY:
Give me a minute, s.
13 please, to wrap things up.
14 (Brief recess.)
-15 MR. McMURRAY:
Dr. Urbanik, I have no 16 further questions.
17 MS. LEUGERS:
We have no questions.
16 18 MR. ZAHNLEUTER:
No questions.
19 MR. BACHMANN:
No questions.
20 MR. McMURRAY:
Will you be waiving 21 signature?
22 MR. BACHMANN:
We would like to see a
/LJ COMPUTER AIDED TRANSCRIPTION / keyword index
74
,)
1 copy.
Can a copy be sent directly to Dr. Urbanik, 2
to save time?
3 (Discussion held off the record.)
4 Time noted:
6:20 p.m.)
5 6
Y 7
8 Subscribed and swom to before me this[d:.y of b9" 10 OW 11 Not-ty Public mmission Expiros g.g7 9Q
~n
(
j 12 My L./
13 14 15 16 17 18 19 20 21 22
,~
/( )'
COMPUTER AIDED TRANSCRIPTION / keyword index
75 1
. C..f Ji_T,_I,_f _I _C,_A _T,_L_0_JJ 2
3 I,;DEBRA~ STEVENS, a shorthand reporter 4
and notary public, within and for the State of New 5'
. York, de hereby certify:
6 4
That THOMAS. URBANIK, I I.- the witness 7
8 whose examination is hereinbefore set forth, was 9
first duly sworn by me, and that transcript of said 10 testimony is a true record ~ of the testimony given by 11 said witness.
12 I further certify that I am not related r
13 to any of the parties to this action by blood or 14 marriage, and that I am in no w'a y interested in the 15 outcome of this matter.
16 17 IN WITNESS WHEREOF,- I have hereunto set 18 my hand this day of NktN 1987.
19 1
_E 20 1
21 DEBRA STEVENS, 22 Certified Shorthand Reporter COMPUTER AIDED TRANGCRIPTION/ keyword index
_ _ _ _ _ _ _ _ _